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ARTICLE · 24 APRIL 2023

Sanctions Weekly Update – Ukraine/Russia Conflict – April 3, 2023

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On March 30, the Office of Foreign Assets Control (OFAC) issued an amended FAQ 1118 on the payment of "exit tax" to the Russian Central Bank and the Ministry of Finance...

GlobalInternational Law
Tamer A. Soliman
Tamer A. Soliman
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Paulette Vander Schueren
Paulette Vander Schueren
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Gretel Echarte Morales
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Anjani D. Nadadur
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Russia/Ukraine Sanctions Update – Week of April 3, 2023

I. US SANCTIONS

  • OFAC Updates FAQ on Payment of Russian "Exit Tax": On March 30, the Office of Foreign Assets Control (OFAC) issued an amended FAQ 1118 on the payment of "exit tax" to the Russian Central Bank and the Ministry of Finance, as may be required by the Russian government before divesting any assets located in Russia. OFAC reiterated that a specific license must be obtained from the OFAC before such payments can be made; however, given the Commission established by Russia to review such divestments may include U.S.-sanctioned individuals, U.S. persons do not need to seek separate OFAC authorization for their Russian buyers to submit an application to the Commission regarding a divestment transaction. Read more>>

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